APPENDIX 4
Memorandum by the National Childminding
Association of England and Wales
CONCERNING THE EFFECTS ON REGISTERED CHILDMINDING
OF CHARGING CHILDMINDERS AND THEIR FAMILIES FOR CRIMINAL RECORD
CHECKS
CHILDREN'S
WELFARE—WHO
PAYS?
1. INTRODUCTION
1.1 The National Childminding Association
(NCMA) is a national charity and membership organisation, speaking
on behalf of 80,000 registered childminders in England and Wales.
Our aim is to promote quality care and learning opportunities
for children of all ages, in a home based setting.
1.2 Childminding is the most popular form
of registered day care and education provision for young children
in the UK, accounting for more than half of all formal childcare
and education for the under fives. Childminders also care for
nearly three times as many school age children before and after
school.
1.3 Nearly 60 per cent of registered childminders
belong to NCMA, which provides direct support and information
to members and works with over 100 local authorities and partnerships
to develop local support networks and training opportunities.
Over the last three years, NCMA has developed two key new initiatives,
aimed at raising the quality of registered childminding—the
"Children Come First" quality assured childminding network
scheme and the CACHE accredited "Certificate in Childminding
Practice". Both these initiatives are highly successful.
1.4 Since April 1998, childminding in England
has been the responsibility of the Department for Education and
Employment (DfEE). The Government has recognised the vital role
that registered childminders play in the care and education of
children by placing registered childminding at the heart of the
National Childcare Strategy.
1.5 Registered childminders are self employed,
home based day care providers, who are registered by the local
authority, under the Children Act 1989, to care for pre school
and school age children of working and student parents.
1.5 Under the Care Standards Act, from autumn
2001 the responsibility for registration and inspection of all
early years services, including childminding will pass to the
Early Years Directorate, which is part of OFSTED.
2. ENSURING THE
SAFETY OF
CHILDREN—THE
IMPLICATIONS OF
THE CRIMINAL
RECORDS BUREAU
ON CHILDMINDER
REGISTRATION
2.1 NCMA welcomes the Government's intention
to ensure the safety and security of children through the setting
up of a Criminal Records Bureau under the Police Act (Part V).
However, the National Childminding Association in England and
Wales has grave concerns that charging individuals for criminal
record checks will deter some individuals from registering as
childminders with local authorities under the Children Act, and
subsequently, the Care Standards Act, requirements.
2.2 However, our concerns are not confined
to the problems with newly registering childminders. As part of
the changeover to the new Early Years Directorate (OFSTED) in
autumn 2001, it appears that all currently registered childminders
and their families will need to have new criminal record checks.
2.3 The consequence of this is likely to
be a fall in the number of childminders choosing to continue their
registration. This would have the unintended effect not only of
losing experienced childminders from the (already shrinking) childminding
workforce but also of diminishing rather than enhancing the safety
and the well being of children. It would also undermine one of
the key principles of the Children Act 1989—which is to
reassure parents about the suitability of those caring for their
children. In summary:
— Charging Registered Childminders
for criminal record checks may reduce the number of Registered
Childminders and increase the number of unregulated
carers of children.
— Charging for criminal record checks
may place the well-being of children in home-based daycare in
jeopardy.
3. WHY IS
CHARGING CHILDMINDERS
FOR CRIMINAL
RECORD CHECKS
A PROBLEM?
Registered Childminders are among the lowest
earners in the UK
3.1 Registered childminding is one of the
four lowest paid occupations in the UK. Each year NCMA conducts
a Pay and Conditions Survey of its members, based on a sample
of 5,000 childminders drawn from every region of England and Wales.
3.2 The latest survey for 2000-01 shows
that the average hourly rate for a registered childminder (for
a childminding placement during normal working hours) is £2.15
per hour, gross. In six of the 12 regions covered by the
survey, the lowest rate is £1.00 per hour. The highest
hourly rate quoted is £5.00, for two regions only, Greater
London and the Home Counties. In these two regions, the rate for
a home cleaner is quoted by agencies at £7.00 per hour.
3.3 At the same time as conducting an annual
survey of Pay and Conditions, NCMA has also introduced a monitoring
question for renewing members on the effects of the Working Families
Tax Credit. Part of the assumption behind the WFTC (Childcare
Tax Credit) is that it will enhance the rates of childcare workers
by providing additional income to working families. However, monitoring
from the first six months indicates that less than 4 per cent
of childminders consider that they are able to charge a higher
hourly rate as a result of the WFTC.
3.4 Childminders are in a unique position
in the world of early years work. Although they are self-employed,
their earnings are circumscribed by the Children Act 1989, and
by the proposed new National Standards for Daycare and Childminding,
which limits the number of children in their care to three children
under the age of five years and three over five (including
their own children). The "average" number of children
care for is in fact 3.4!
3.5 This requirement is intended to encourage
a high quality of individual care and attention and to ensure
the safety of young children, but it limits earnings and gives
no scope to cover increased expenditure.
3.6 Currently the cost of criminal record
checks—apart from local authority administration—is
borne by government. Under the new proposals, both the administration
and costs of these checks will fall on the individual childminder
and their families. The new level of check required under the
CRB regulations would be the enhanced check for those in
paid, or unpaid positions, which involve regular contact in "caring
for, training, supervising or being sole charge of persons aged
under 18". Currently, the costs are estimated at £15-£20
per check.
3.7 Research funded by the DfEE in 1998
showed that the overwhelming majority of childminders have spouses
and children; and that the median age of childminders is 35-44.
It is not unusual therefore for up to four members of a childminder's
household—where for example there are teenage children—to
require checking as a part of the registration process under the
Children Act. For experienced childminders, with husbands/ wives,
partners and teenage children, the costs could be in the order
of £60 to £100.
3.8 Mrs. W, the only registered childminder
in a village near Towcester, Northampton, caring for children
from four different families, is such a case. As the sole wage
earner in the family, she would be liable to pay for five criminal
record checks, for herself, her husband (who is suffering from
ill health and currently not working) and three adult children,
two of whom are at college. These costs would put a real strain
on her family income and may lead to her considering alternative
employment.
4. WHAT EFFECTS
COULD CHARGING
FOR CRIMINAL
RECORD CHECKS
HAVE ON
REGISTERED CHILDMINDING
AND THE
SAFETY OF
CHILDREN?
4.1 The possibility of further charges could
therefore tip the balance for many existing childminders and inadvertently
encourage unregistered childminding, compromising the safety of
children and undermining and the new National Standards for Daycare.
This is a real fear and was the subject of an emergency resolution
from Sheffield Childminding Association (one of seventy local
associations affiliated to NCMA) at NCMA's Annual General Meeting
in November 2000.
4.2 The imposition of charges could further
exacerbate the fall in registered childminders in England and
Wales, where numbers have decreased by 25 per cent in the last
three years. It would also compromise the government's efforts
and investment in improving both recruitment and retention in
the childminding sector, and inhibit their plans for an additional
120,000 childminding places by 2004.
4.3 Although the government has introduced
a "start-up" grant for new childminders, the grant is
not available in Wales, or in every part of England. Neither does
it address the crucial issue of retaining experienced childminders.
30 per cent of NCMA's members have been childminding for more
than five years, many of them for more than 10 years. The impact
of paying for criminal record checks, on them and their families,
should not be underestimated.
5. CHILDREN'S
WELFARE—THE
REAL COSTS
5.1 Since debate on the costs of criminal
record checks began some years ago with the publication of the
Police Bill, the government of the day has resisted the call to
exempt childminders from charges was on grounds of "cost".
They argued that the exemption could not be justified on public
expenditure grounds.
5.2 However, the cost of providing free
criminal records checks to all existing registered childminders
needs to be set against the potential costs of not providing them.
These could be a great deal higher, in terms of additional costs
arising from an increase in unregistered childminding, in terms
of enforcement action and child protection investigations.
5.3 The real cost to children could be the
loss of experienced childminders and the growth of the unregulated
sector, with all the dangers that such a scenario poses to children's
welfare. At a time when so many government strategies rely on
increasing the numbers of registered carers to enable families
to participate in work and training while their children are cared
for in a safe environment, the prospect of charging childminders
and their families for criminal record checks seems deeply
unwise.
Gill Haynes OBE
Chief Executive
January 2001
| 
